ML20246H432

Affidavit of Gs Thomas.* Discusses Low Power Testing of Plant.W/Certificate of Svc

ML20246H432
Person / Time
Site:	Seabrook
Issue date:	05/10/1989
From:	George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20246H366	List: ML20246H363 ML20246H432
References
OL-1, NUDOCS 8905160097
Download: ML20246H432 (12)

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UNITED STATES OF AMERICA before the NUCLEAR REGULATORY COMMISSION

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 NEW HAMPSHIRE, et al. ) 50-444-OL-1

) (On-Site Emergency (Seabrook Station, Units 1 and 2) ) Planning and Safety

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AFFIDAVIT OF GEORGE S. THOMAS

' GEORGE S. THOMAS, being duly sv.orn says:

1. I am employed by New Hampshire Yankee Division ("NHY") of Public Service Company of New P.ampshire ("PSNH") as Vice President - Nuclear Production. I am responsible for the operation and operational support of Seabrook Station. I report directly to President and Chief Executive Officer of NRY, Edward A. Brown. I was elected to this position in May, 1982. From September, 1980, until May,1982, I held the position of Nuclear Production Superintendent for PSNH. In that position, I had the overall responsibility for the operation of Seabrook Station from the corporate office. From 1977 until September, 1980, I held the position of startup engineer for the Seabrook Project and the Yankee Atomic Electric Company. From 1969-1977, I held various positions for Yankee Atomic Electric Company and Vermont Yankee Nuclear Power Corporation including 8905160097 890510 1 PDR ADOCK 05000443 i G PDR-

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t Assistant Station Superintendent of Vermont Yankee Nuclear Power Station.

In that position, I was directly responsible for operation, maintenance and technical support of Vermont Yankee Nuclear Power Station. From 1967-1969, I worked for the Babcock and Wilcox Company as a design engineer and per-formed thermofluid studies for the design of light water and liquid metal reactor components. I received a Bachelor of Science degree from the University of Massachusetts in Mechanical Engineering, graduating cum laude in 1965. I received a Master of Science Degree in Mechanical Engineering f rom Northeastern University in 1982. i

2. Low power testing is a seriet of procedures for testing a nuclear reae:or by measuring the nuclear physics related characteristics of the reac;or. During testing, the plant's operating systems are at the normal  ;

plan: operating temperature (557'F) and pressure (2235 psig) conditions.

During low power testing the reactor heat output is limited to 5% of the design power levels.

3. In October, 1986, the Seabrook Project received a 40 year operating license from the NRC with a restriction to zero power operation. Prior to that time, all major systems at Seabrook Station, with the exception of the reactor itself, had been subject to extensive testing. Previous testing included hot functional testing in which the plant was brought up to normal temperature and pressure through the use of mechanical pumps and heaters.

The low power testing program is the last major test milestone facing Seabrook Station prior to power generation.

4. The low power testing progran can be broken down into three parts:

preparation, heatup, and low power tests.

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5. The preparation stage was initiated in October,1988.. During this phase systems were taken out of a layup condition, lined up and prepared for.

I heatup and low power tests. During this period over 200 surveillance tests were conducted, many if which are required by regulation before reaching initial criticality. .\t present, plaat systems and equipment are being maintained in a state of seadiness for heacup.

6. The second stage, heatup, has an estimated two. week duration.. It requires bringing the plant to normal ope:ating temperature and pressure, completing open retest activities and preparing for initial criticality.

During this phase, over 30 retests must be performed on equipment that has been adjusted or modified since the previous hot functional testing. The retesting is.necessary to verify operation in accordance with design requirements. For example, the steam driven emergency feedwater pump, an important safety component, must be, retested and the Post-Accident Sampling System has been modified and must undergo additional operational tests.

7. During the low power test phase, the plant will be brought to initial criticality and testing will be performed to measure the nuclear physics related characteristics of the reactor core. The low power testing j verifies that the nuclear characteristics of the reactor core assumed in the safety analysis'correlare well with actual data obtained during the low power testing program.

8. Although certain tests can be conducted when the plant is under hot functional conditions, several important tests can only be conducted after the plant goes critical. A key example is Seabrook's fixed and movable incore detector system. This system is found within the reactor 1

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. vessel, and it performs nuclear measurements of the reactor core. Because

- the' system employs certain design characteristics which are unique to Seabrook, it is important to test it early so thatL any adjustments required to be made would not delay full power operation.

9. Following completion of lou power testing, the reactor will be shut down and non-nuclear testing of the main turbine will be conducted l over a period of approximately one week. Upon completion of that testing the plant will be cooled .down to approximately 125*F.

10. Using the period between lov and full power licensing to make plant equipment and procedure adjustments that were identified as a result of low power testing will provide greater assurance of a trouble-free ascension to full power and coc=ercial operations. For example, the plants listed below identified various conditions during startup that resulted in full power delays:

Approximate Plant Condicion Length of Delay South Texas Project Hardwtre problems (e.g. Five months wate ha=cer in the main and auxiliary feedwater sys tems)

Calvert Cliffs Excassive pressure drop Two months Unit 1 acrass reactor core Palo Verde 3 Excassive leakage in Three months the Reactor Coolant Pump Shaf: Seals Braidwood 2 Certain greases used in Two months motor operated valves were inco:patible San Onofre 2 Pressurizer spray valve Three weeks repair and cleaning of evntrol red drive mechanises 1

, 11. Additional benefits to performing low power testing at this time o are as follows: (1) it allows for evaluation, assessment and familiarize-g% tion with Technical Specifications and implementing procedures for the op h tion of the plant at low power; and (2) operators and plant staff gain experil y on the actual plant in a critical, but low power, operating mode.

12. If 11 power testing is delayed until a full power license is issued,thelowhMr tests will cause, at minimum, a one week delay in commercialoperation.Qvenrelativelyminorcorrectionscouldcausean additional day-for-day sl!.p in the schedule, which could result in loss of N

revenue at the rate of about $2.8 million to $3.6 million per day, s

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13. The low power test program at,Seabrook Station will result in a negligible radiological?. impact. Based on experience provided by other nuclear power plants, if plant contamination levels were measurable, they would consist of short lived isotopes that would decay within 1-2 weeks.

Af ter this decay period no significant levels of radioactive material would be found within the plant except for the reactor vessel and as4ciated core internals, reactor fuel, and certain process filters. Thus, there is no long-term contamination of the plant from low power testing.

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14. Another common misconception is that the power plant at Seabrook Station, which is already completely constructed, could be converted into a 1

non-nuclear energy generating plant. The term " conversion" is a misnomer. l l

Conversion would actually amount to a total projer.t abandonment since none_ j I

of the nuclear portions of the plant would be used in a conversion. ]

Therefore, alternative courses of action for use of the facility are not, l i

foreclosed by the performance of low power testing.

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(' 15. The power that Seabrook S:ation can produce is needed now to l I satisfy New England's growing demar.d for power, which is experiencing one l

l of the highest rates of growth in :he nation. Since August of 1987, New I

En81 and has experienced severe shortages of electrical power during both

- the summer and winter peak demand periods. It was through aggressive action by the New England Power Po:1 (NEPOOL), which manages the power supply for New England, that servi:e throughout the area was maintained.

Emergency actions taken to decreast the high demand incladed enforcement.of interruptible power contracts with industrial users, voltage reductions, public appeals to cut back on elec:ricity usage, and intentional brownouts  ;

I instituted to avoid complete black:uts in specific geographical areas. A s tudy commissioned by the Massachusetts Cha:cbers of Commerce in September, 1988, estimated that the total impact of non-accidental energy supply shortages on the Massachusetts business community alone, over a 12 month period, was approximately $86.8 mi' lion.

16. The power shortage situation is not likely to change for the ]

better anytime soon. New England's economy has been growing tremendously, ,

l with a parallel increase in electrical energy consumption (KWR) and peak .

electrical power demand (MW). This growth has placed an unprecedented I strain on the New England electrical system since there has not been a corresponding increase in electrical generating facilities. With the decrease in the electrical reserve margin has come an increase in the frequency of use of emergency operating procedures. During the oil crisis of the early 1970's, these emerge:cy operating procedures were used on many occasions. As this crisis eased and non-oil generating f acilities

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were brought into production, emergency operating procedures were not used

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.again in New England from 1974.through 1983. Emergency load relief measures were implemented by NEPOOL more times in 1988 than at any time i since the'early 1970's.

17. New England's electrical energy consumpr. ion increased 5.2% in 1988 I nearly equaling the 5.3% growth experienced in 1987. Since 1983, electrical energy consumption has grown at a compound annual growth rate of 4.6%.

Along with growth in energy consumption, winter and summer peak demand has been increasing at an average rate of 4.5% per year since 1983.

18. With the continuation of sustained load growth in New England during 1988 and into 1989, NEPOOL and New England utilities were required to make optimum use of virtually every generator and transmission line in the New England region.

19. Based on a NEP00L forecasted seasonal peak load report for the period of March, 1989, to March, 1990,.it is projected that New England will experience capacity deficiencies in 42 of 52. weeks without. power from Seabrook. New England is in a serious capacity shortage situation. NEPOOL is unable to schedule planned outages for four months (su=ner, July and August, 1989, and winter, December 15 - February 15,'1990) due to the fore-casted load. This places heavy maintenance demands in the Spring and Fall which results in additional capacity deficiencies within this time period.

The bottom line: Capacity shortages throughout the entire year.

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20. A report published i: November, 1988, by the State of New Hampshire, State Electrical .E ergy Needs Planning Committee, recognized the importance of Seabrook operation in meeting the electrical demands. As stated under their recommenda: ions,'"The Committee urges the Nuclear Regulatory Commission to prom;:tly resolve all outstanding questions relating to the Seabrook Nuclear Power Plant".

HjM $ l mM George S. Thomas STA!! OF SEW HAMPSHIRE Rockingham, es. May 10, 1989 George S. Thomas, being en oath, deposes and says that he is the author of the foregoing affidavit and that the statements set forth therein are true to the best of his k:owledge.

Befere me.

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Notary Pu%dc My Commission Expires: 3-( *30

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[}7f f4 D PCTID yA CERTIFICATE OF SERVICE 2 g 1019BB" u ,f I, Thomas G. Dignan, Jr., oneoftheattorneys\(fprAFet"*'r, '

Applicants herein, hereby certify that on May 10, 196,9, I'made service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or where indicated, by '

depositing in the United States mail, first class postage' paid, addressed to) the individuals listed below:

Lando W. Zech, J r. , Chairman Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North One White Flint North 11555 Rockville Pike Rockville, MD 20852 11555 Rockville Pike Rockville, MD 20852 Kenneth M. Carr, Commissioner James R. Curtiss, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission one White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Kenneth C. Rogers, Commissioner William C. Parler, Esquire U.S. Nuclear Regulatory General Counsel Commission Office of the General Counsel One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Thomas S. Moore Marjorie Nordlinger, Esquire Atomic Safety and Licensing Office of the General Counsel Appeal Panel One White Flint North U.S. Nuclear Regulatory )

11555 Rockville Pike Commission Rockville, MD 20852 East West Towers Building 4350 East West Highway Bethesda, MD 20814

4 Administrative Judge Ivan Smith Administrative Judge Kenneth A.

Chairman, Atomic Safety and McCollom Licensing Board 1107 West Knapp Street U S. Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Richard F. Administrative Judge Peter B.

Cole, Atomic Safety and Bloch, Chairman, Atomic Licensing Board Safety and Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, Md 20814 Dr. Jerry Harbour Administrative Judge Emmeth A.

Atomic Safety and Licensing Luebke Board 4515 Willard Avenue U.S. Nuclear Regulatory Chevy Chase, MD 20815 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Mr. Richard R. Donovan Diane Curran, Esquire Federal Emergency Management Andrea C. Ferster, Esquire Agency Harmon, Curran & Tousley Federal Regional Center Suite 430 130 228th Street, S.W. 2001 S Street, N.W.

Bothell, WA 98021-9796 Washington, DC 20009 Robert R. Pierce, Esquire John P. Arnold, Esquire Atomic Safety and Licensing Attorney General Board George Dana Bisbee, Esquire U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814

Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North East West Towers Building 15th Floor 4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852

• Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General Maplewood Avenue Department of the Attorney P.O. Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Floor Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801

• Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &

Washington, DC 20510 Rotondi (Attn: Tom Burack) 79 State Street-Newburyport, MA 01950 i

• Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.

Concord, NH 03301 77 Franklin Street (Attn: Herb Boynton) Boston, MA 02110

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i Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street  !

Agency Newburyport, MA 01950 500 C Street, S.W.

Washington, DC 20472 1 Gary W. Holmes, Esquire Richard A. Hampe, Esquire i Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301 Judith H. Mizner, Esquire Ashod N. Amirian, Esquire 79 State Street, 2nd Floor 145 South Main Street Newburyport, MA 01950 P.O. Box 38 Bradford, MA 01835 F-fS, - -- ) ..

Thomas G.' Dig g Jr.

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